The debate on return hubs has gained prominence in Belgium in recent months. On 16 September 2026, Prime Minister Bart De Wever confirmed that Belgium wished to make use of return hubs, subject to respect for human rights and the exclusion of minors. On 6 October, Minister for Asylum and Migration Anneleen Van Bossuyt reiterated the government's support for the legal possibility of establishing such hubs, while indicating that no discussions had yet taken place with potential partner countries. On 3 November, the UN High Commissioner for Human Rights expressed concerns about the human rights risks associated with transferring migrants to third countries. More recently, a resolution was submitted to the Belgian Chamber of Representatives (DOC 56 1697/001), calling on the federal government to explore the establishment of return hubs jointly with other Benelux countries.

In their position paper, Vluchtelingenwerk Vlaanderen and 11.11.11 put forward three main arguments against Belgian investment in return hubs:

• Serious risks to human rights and legal protection: the organisations warn that transferring people to third countries could expose them to arbitrary or prolonged detention, refoulement or chain refoulement, where a person is subsequently transferred to another country in which they risk persecution or serious harm. They also stress that formal assurances from partner countries are not sufficient to guarantee respect for fundamental rights. Effective independent monitoring, access to legal assistance and the possibility of challenging decisions before an independent court are essential to ensure that people transferred to these facilities are adequately protected. Belgium's human rights obligations, they argue, do not cease to apply when people are transferred outside EU territory.
   
• Diplomatic vulnerability: establishing return hubs would require Belgium to rely on the continued cooperation of third countries. The organisations point out that partner countries may change their political priorities or impose new conditions, potentially exposing Belgium to political pressure. Such dependence could also create inconsistencies with Belgium's foreign policy and its commitments to human rights.
   
• Limited practical and financial added value: the organisations question whether return hubs can deliver effective and sustainable results. They refer to previous initiatives, including the Italy-Albania arrangement and the former UK-Rwanda plan, which encountered legal and operational difficulties and failed to produce the expected results. They also argue that return hubs do not address the structural obstacles that often prevent returns, such as difficulties establishing a person's identity, obtaining travel documents and securing cooperation from the authorities of the country of origin. Furthermore, increasing coercion does not necessarily lead to more sustainable returns. In their view, the effectiveness and financial feasibility of return hubs have not been sufficiently demonstrated, particularly in light of the considerable resources required to establish and operate them.

Rather than investing in return hubs, Vluchtelingenwerk Vlaanderen and 11.11.11 call on the Belgian government to strengthen alternatives to detention and invest in more individualised and sustainable approaches. They advocate providing people with tailored guidance to assess their individual circumstances and explore realistic prospects for the future. These may include voluntary return and reintegration where appropriate, as well as a residence solution where legal grounds exist. The organisations argue that return policy should focus not only on the implementation of return decisions, but also on achieving sustainable outcomes that take account of individual circumstances.

For further information, please consult (in Dutch) the full position paper of Vluchtelingenwerk Vlaanderen and 11.11.11 on return hubs.